Colorado Juvenile Criminal Law

The importance of motions in Colorado Juvenile Criminal Cases cannot be understated. This article addresses a basic motion – a so called “Terry Stop” motion to suppress evidence. This motion is based on an illegal stop made by the police – including some questions to ask the police in the motion to suppress hearing. Also included are suggestions for other kinds of juvenile case motions.

Colorado Juvenile Criminal Law – Police Stops – Terry Stop Questions… (When the police stop you in or out of an automobile)

Was the juvenile arrested before or after the police stopped and frisked her?

Was he arrested pursuant to a traffic stop?

If so, refer to “Automobile Arrest Questions.”

What did the police look like?

How many were there?

Does the juvenile remember their names?

What specifically did the police find?

Did the police take anything with them?

Did they give her or anyone else a receipt?

Where is the receipt?

Was he or anyone else searched or frisked?

If so, where?

Did the police have a search or arrest warrant?

Was he or anyone else arrested before or after the search?

Did the police ever threaten her in any way?

Did he or anyone else say anything to the police? If so, what admissions?

Automobile Arrest Questions

Who owns the car?

If the juvenile did not own the car, had the owner given permission to the driver or passenger of the car to drive the car?

Who had permission to drive the car?

When the juvenile was arrested, was he inside the car?

Outside the car?

Where was the car?

If the he juvenile was inside the car at the time of arrest:

Was he the driver?

Was there anyone else in the car at the time?

Who was sitting where?

What was everyone doing?

Is he licensed to drive?

Did the juvenile have her driver’s license at the time?

How did he react to the police?

Did he try to elude the police?

Did he try to hide or get rid of anything?

Was anything in the car? What?

Where exactly was it in the car?

If he was not in the car when arrested:

Where was he arrested in relation to the car (diagram)?

Did he leave the car before or after the police arrived?

Did the police follow her to the car?

Did the police force open the car or any part of the car?

Did they use keys? If they used keys, how did they get the keys?

Initial Arrest Questions

Who, what, when, where, why, & how?

Who was with the juvenile when he was arrested?

Were they also arrested? (witness information.)

Was the juvenile injured during or after arrest? (If yes, describe the perpetrators, their conduct, and the resulting injuries in detail)

Did the juvenile go to the hospital? If so, which one? For how long?

Did anyone treat the juvenile for injuries? Who?

Were there any eyewitnesses? (get witness information.)

When was the juvenile arrested (date and time)?

Where exactly was the juvenile arrested? (Diagram)

Did the police have a warrant?

What did they say they were charging him with?

What question(s) did they ask him?

What did he say in response (to each question)?

Other Suggested Juvenile Criminal Motions

Motion to Dismiss for Failure To State an Offense

Motion to Dismiss for Lack of Jurisdiction

Motion to Dismiss for Failure To Establish Venue

Motion to Dismiss (for lack of specificity)

Motion to Dismiss Because the Statute of Limitations Has Lapsed

Motion to Dismiss for Double Jeopardy Violation

Motion for Severance (of multiple counts)

Motion for Severance (of the joined trial)

Motion for a Change of Venue

Motion for a Change of Judge

Motion to Dismiss for Lack of Speedy Trial

Motion for a Jury Trial

Motion to Suppress Physical Evidence (Fourth Amendment Issues)

Motion to Suppress a Confession or Statements

Motion to Suppress an Identification

Motion to Strike Evidence

Motion for Protective Order

Motion for Discovery – or for Additional Discovery

Motion for a Bill of Particulars

Motion for In Camera Inspection

Motion to Quash a Subpoena/ Subpoena Duces Tecum

Motion for a List of Witnesses

Motion for Disclosure of Preferential Agreements with Witnesses

Motion for Disclosure of Criminal Records of Witnesses

Motion for Production of Mental Health Records of Complainant

Motion for Disclosures Relating to Expert Witnesses

Motion for Discovery and Inspection of Scientific Tests and Reports

Motion to Compel Discovery

Motion for Sanctions for Failure to Comply with Discovery

Motion to Sequester Witnesses

Expert/Special Witnesses

Motion for Court Payment of Expert Witness

Please Call:

H. Michael Steinberg has been a Colorado criminal law specialist attorney for 30 years. For the First 13 years of his career, he was an Arapahoe – Douglas County District Attorney Senior prosecutor. In 1999 he formed his own law firm for the defense of Colorado criminal cases.

In addition to handling tens of thousands of cases in the trial courts of Colorado, he has written hundreds of articles regarding the practice of Colorado criminal law and frequently provides legal analysis on radio and television, appearing on the Fox News Channel, CNN and Various National and Local Newspapers and Radio Stations. Please call him at your convenience at 720-220-2277

If you have questions about…

Colorado Juvenile Criminal Law

… in the Denver metropolitan area and throughout Colorado, attorney H. Michael Steinberg will be pleased to answer those questions and will provide quality legal representation to those charged in Colorado adult and juvenile criminal matters… as regards Colorado Juvenile Criminal Law.

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